2025-cv-04196

2025-cv-04196 Natasa Ilincic v. The Partnerships and Unincorporated Associations Identified On Schedule A

Date :4/17/2025
Court :Northen District of Illinois
Law FirmKeith

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Date

Document

1

April 17, 2025

COMPLAINT filed by Natasa Ilincic; Filing fee $ 405, receipt number AILNDC-23361458.

(Exhibit 1)

2

April 17, 2025

SEALED DOCUMENT by Plaintiff Natasa Ilincic Schedule A to Complaint 1

3

April 17, 2025

CIVIL Cover Sheet

4

April 17, 2025

ATTORNEY Appearance for Plaintiff Natasa Ilincic by Keith A. Vogt

5

April 17, 2025

ATTORNEY Appearance for Plaintiff Natasa Ilincic by Adam Grodman

6

April 17, 2025

ATTORNEY Appearance for Plaintiff Natasa Ilincic by Cameron Eugene Mcintyre

7

April 17, 2025

ATTORNEY Appearance for Plaintiff Natasa Ilincic by Christopher Romero

8

April 17, 2025

ATTORNEY Appearance for Plaintiff Natasa Ilincic by Monica Rita Martin

9

April 17, 2025

ATTORNEY Appearance for Plaintiff Natasa Ilincic by Yanling Jiang

10

April 17, 2025

ATTORNEY Appearance for Plaintiff Natasa Ilincic by Yi Bu

April 17, 2025

CASE ASSIGNED to the Honorable Jorge L. Alonso. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. Case assignment: Random assignment. (Civil Category 3).

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order.

NEW PARTIES: jaiq, pengqins, yanongsh, zhongxiangshiranxiangandianzishangwuyouxiangongsi, XuShiQi66, GuangZhouWuBoBaiHuo, JIZHONGYIMAIYIFU, fuyanggaoyongwangluokejiyouxiangongsi, GuangZhouRuiJiaMaoYiYouXianGongSi, xieweixiongbeimei, BeiJingLuFengKeJiYouXianGongSi, Zheng7364Li Hong, Wax home, kunmingmudingdianzishangwuyouxiangongsi, GuangZhouZhaoLiMaoYiYouXianGongSi, JinLongGuangGao, Taihe Xianfu E-commerce Studio Sole Proprietorship, Diamond TT, zafeng, CHUANYU2024, lixiaolongmaiwazi, Defendant No. 22, HuiZhouShiLianJiaKeJiYouXianGongSi, GUANGZHOUZHONGYISHANGMAOYOUXIANGONGSI, shenyefanshangmaobaihuoxiaodian, BackBerriesBBeau, BAOYONGAO, Binyeen, Stantini, Autlry, JUNXINhuihuahaibao, zhushijie2024, HouYuLongWireless, HuoYing, CYK womens wear store, Chengpeak frock, Shunky Store, hefeigailingdianzishangwu, FOSHIN Design, rerer, WEIGUO and yuwudianzi added to case caption.

11

April 17, 2025

MOTION by Plaintiff Natasa Ilincic for leave to file under seal

12

April 17, 2025

MOTION by Plaintiff Natasa Ilincic for leave to file excess pages

14

April 17, 2025

MEMORANDUM in Support of 13 Exparte Motion

Declaration of Keith A. Vogt

Exhibit 1-2, of Keith A. Vogt's Declaration

Declaration of Natasa Ilincic

(Exhibit 1, of Natasa Ilincic's Declaration)

15

April 17, 2025

SEALED EXHIBIT by Plaintiff Natasa Ilincic Sealed Exhibit 2, Declaration of Natasa Ilincic regarding memorandum in support of motion, 14

Exhibit 2-1

Exhibit 2-2

Exhibit 2-3

(Exhibit 2-4)

16

April 17, 2025

Presentment for Exparte Motion 13 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file excess pages 12, motion for leave to file 11 before Honorable Jorge L. Alonso on 4/24/2025 at 09:30 AM.

17

April 17, 2025

[CORRECTED] Notice of Motion for presentment of Exparte Motion 13 and NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file excess pages 12, motion for leave to file 11 before Honorable Jorge L. Alonso on 4/24/2025 at 09:30 AM.

19

April 23, 2025

MINUTE entry before the Honorable Jorge L. Alonso: The Court strikes the 4/24/25 hearing. Plaintiff's ex parte motions 11, 12, and 13 are granted. The Plaintiff's written submissions establish that if Defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating Plaintiff's interests in identifying Defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to Plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the Plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to Defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with Defendants. Expedited discovery is warranted to identify Defendants and implement the asset freeze. If any Defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The Court finds that security in the amount of $42,000, $1,000 per Defendant, is sufficient to secure the injunctive relief. Telephonic status hearing set for 5/6/25, at 9:30 a.m. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

20

April 23, 2025

SEALED TEMPORARY Restraining Order. Signed by the Honorable Jorge L. Alonso on 4/23/2025. Notice mailed by Judge's staff

22

April 23, 2025

SUMMONS Issued (Court Participant) as to Defendant jaiq and all other Defendants identified in the Complaint

24

April 30, 2025

MOTION by Plaintiff Natasa Ilincic for preliminary injunction

25

April 30, 2025

MEMORANDUM by Natasa Ilincic in support of motion for preliminary injunction 24

Declaration of Keith A. Vogt

(Exhibit 1, of Keith A. Vogt's Declaration)

26

April 30, 2025

NOTICE of Motion by Keith A. Vogt for presentment of motion for preliminary injunction 24 before Honorable Jorge L. Alonso on 5/6/2025 at 09:30 AM.

27

April 30, 2025

SUMMONS Returned Executed by Natasa Ilincic as to The Partnerships and Unincorporated Associations Identified on Schedule A on 4/30/2025, answer due 5/21/2025.

(Declaration of Service)

28

May 6, 2025

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held and continued to 6/5/25 at 9:30 a.m. Telephonic motion hearing held. Plaintiff's Motion for entry of a preliminary injunction 24 is granted. Enter Preliminary injunction order. Plaintiff is ordered to add all Defendant names listed in the Schedule A to the docket within three business days. Instructions can be found on the court's website at www.ilnd.uscourts.gov. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the access code is 1804010308. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Notice mailed by Judge's staff

29

May 6, 2025

PRELIMINARY Injunction Order. Signed by the Honorable Jorge L. Alonso on 5/6/2025. Notice mailed by Judge's staff

30

May 22, 2025

NOTICE of Voluntary Dismissal by All Plaintiffs as to [certain] defendants

31

May 22, 2025

MOTION by Plaintiff Natasa Ilincic for default judgment as to the Defendants Identified in First Amended Schedule A

32

May 22, 2025

MEMORANDUM by Natasa Ilincic in support of motion for default judgment 31

Exhibit 1

Exhibit 2

(Declaration of Keith A. Vogt)

33

May 22, 2025

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 31 before Honorable Jorge L. Alonso on 6/5/2025 at 09:30 AM.

35

June 5, 2025

MINUTE entry before the Honorable Jorge L. Alonso: Telephonic status hearing held. Telephonic motion hearing held. Plaintiff's Motion for entry of default and default judgment against the Defendants identified in first amended schedule A 31 is granted. Enter Final Default Judgment Order. Civil case terminated. Notice mailed by Judge's staff

36

June 5, 2025

FINAL Default Judgment Order. Signed by the Honorable Jorge L. Alonso on 6/5/2025. Notice mailed by Judge's staff

37

June 6, 2025

SATISFACTION of Judgment as to defendant no. 28 Binyeen and defendant no. 29 Stantini

38

June 6, 2025

MAILED copyright report to Registrar, Washington DC.

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